Coast Waste Management Association

Personal Information Protection Policy

At the Coast Waste Management Association, we are committed to providing our members and network associates with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our members and associates, protecting their personal information is one of our highest priorities.

While we have always respected our members and associates privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our members and associates of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting members and associates personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our members and associates personal information and allowing our members and associates to request access to, and correction of, their personal information.

Scope of this Policy
This Personal Information Protection Policy applies to the Coast Waste Management Association (CWMA) and its subsidiaries.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of CWMA.

Definitions
Personal Information –means information about an identifiable individual including name, email address, phone number and employer Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that CWMA complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the members and associates voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect members and associates information that is necessary to fulfill the following purposes:

• To verify identity;
• To register members or associates for an event or conference;
• To deliver requested products and services;
• To guarantee a meeting or conference registration;
• To enrol the in the membership a program;
• To send out association membership information;
• To contact our members and associates for sponsorship;
• To ensure a high standard of service to our members and associates;
• To meet regulatory requirements;
• To identify members and associates preferences;
• To verify creditworthiness;
• To collect and process accounting transactions;

Policy 2 – Consent

2.1 We will obtain members and associates consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically or through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the members and associates voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a members and associates is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of events, new services or products, or sponsorships and the members and associates does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), members and associates can withhold or withdraw their consent for CWMA to use their personal information in certain ways. A members and associates decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the members and associates in making the decision.
2.5 We may collect, use or disclose personal information without the members and associates knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual’s life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose members and associates personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
• To conduct client, customer, member surveys in order to enhance the provision of our services;
• To contact our members and associates directly about products and services that may be of interest;
3.2 We will not use or disclose members and associates personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell members and associates lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use members and associates personal information to make a decision that directly affects the members and associates, we will retain that personal information for at least one year so that the members and associates has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain members and associates personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that members and associates personal information is accurate and complete where it may be used to make a decision about the members and associates or disclosed to another organization.
5.2 Members and associates may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer [or designated individual.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the members and associates correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of members and associates personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that members and associates personal information is appropriately protected:
• the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying members and associates personal information such as;
• deleting electronically stored information
• shredding documents
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Members and Associates Access to Personal Information

7.1 Members and associates have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell members and associates how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the members and associates of the cost and request further direction from the members and associates on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the members and associates in writing, providing the reasons for refusal and the recourse available to the members and associates.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer or designated individual is responsible for ensuring CWMA compliance with this policy and the Personal Information Protection Act.
8.2 CWMA’s, members and associates should direct any complaints, concerns or questions regarding CWMA’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the members and associate may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for CWMA Privacy Officer:

Executive Director
Coast Waste Management Association
Suite 109-1834C Oak Bay Avenue
Victoria, BC V8R 0A4

info@cwma.ca
Tel: 250 733 2213